VDROOM Privacy Policy

Last Revised: July 27, 2017

VDROOM LTD. (“VDROOM", "Company" “we” or "us") respects the privacy of the users of its Platform (as defined in our TOU) (“User” or “you”) and is committed to protect the personal information that its Users share with it. We
believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Platform.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use ("TOU"), into which this Privacy Policy is incorporated by reference.

Your Consent (PLEASE READ CAREFULLY!)

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE PLATFORM, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE "PRIVACY POLICY"), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL
INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS, DOWNLOAD OR USE THE PLATFORM.

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL
INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.

PLEASE NOTE: BY AGREEING TO THE TERMS, YOU PROVIDE YOUR FREE AND VOLUNTARY CONSENT TO THE RECEIPT OF COMMERCIAL MATERIALS AND MARKETING MATERIALS. PLEASE SEE SECTION 13 BELOW.

Which information we may collect on our Users?

We may collect two types of data and information from our Users:

Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-personal
Information is
any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Platform. Non-personal Information which
is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Platform, type of operating
system, User's 'click-stream' or searches on the Platform, type and version of browser, keyboard language, screen resolution, etc.

Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

Users of the Platform automatically provide their IP address mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.

Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User when he/she wants to contact us: full name and e-mail address.

For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms and the Privacy Policy.

How Do We Collect Information on Our Users?

We use a few methods:
We collect information through your entry and use of the Platform. In other words, when you are using the Platform we are aware of it and may gather, collect and store the information relating to such usage.
We collect information that you decide to provide us voluntarily. For example, we collect Personal Information that you voluntarily provide when you fill forms on the Platform. We may gather, collect and store the Personal
Information
either
independently or through the help of our authorized third-party service providers.

What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:

Use it for statistical and research purposes and for customization and improvement of our Platform.

Personal Information is collected in order to:

Provide and personalize our services to our Users.

Allow third party suppliers (e.g. hotels, rental apartments and holiday resorts) selected by you, to contact you for the purpose of making reservations or bookings.

Provide Users with commercial materials, updates about new offerings or services, etc.

Reply to User's questions or requests.

Provide technical support.

Verifying User's identity for the purpose of dealing with inappropriate or illegal uses of our Platform.

Determine general geolocation information (i.e., country) from which the User's computer is connected to the Internet in order for us to know the general location of our Users as well as in order to safeguard our
Platform.

Sharing Information with Third Parties

VDROOM may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, or to
conduct investigations of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User's support requests; (e) respond to claims that the
Platform's activity or any Content violates third-party rights; (f) to protect the rights, property, or personal safety of VDROOM, its Users, or the general public; (g) when VDROOM is undergoing any change in control,
including by means of merger, acquisition or purchase of all or substantially all of its assets; (h) to collect, host and/or manage your Personal Information through VDROOM's authorized third parties service providers
(including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection
laws as your jurisdiction; (i) to store or process your Personal Information through VDROOM's affiliated companies, which may be located in a country that does not have the same data protection laws as your
jurisdiction; and/or (j) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, VDROOM may transfer and disclose Non-personal Information to third parties at its own discretion.

Deletion or Modification of Personal Information

If for any reason you wish to delete or modify your Personal Information please send us an e-mail with adequate detail of your request to legal@vdroom-travel.coml
and we will make reasonable efforts to modify or delete
any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes for which
such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations and to resolve disputes or to enforce
our Terms, all as permitted under any applicable privacy laws.

Aggregated and/or anonymous information derived from your use of the Platform may remain on our servers indefinitely.

Minors

The Platform is intended for Users over the age of thirteen (13). Therefore, VDROOM does not intend and does not knowingly collect Personal Information from children under the age of thirteen (13) and does not wish to
do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the Platform. If we learn that we collected Personal Information from
children under the age of thirteen (13) we will delete that information as quickly as possible. Please contact VDROOM at
legal@vdroom-travel.coml if you have reasons to suspect that VDROOM collected Personal Information from children under the age of
thirteen (13) and will delete that information as quickly as possible.

Security

We take reasonable measures to maintain the security and integrity of our Platform and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and
internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of
your Personal Information will never occur.

VDROOM SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.

Third Party Service Providers

We may be using third party software or service in order to collect, host, store and/or process the information detailed herein. VDROOM uses commercially reasonable efforts to engage with third parties that post a
privacy policy governing their collection, processing and use of non-personal and personal information. Such software include without limitation, the Amazon cloud services which its privacy policy can be found at:
AWS Privacy Policy. However, we do not control such third party service providers. Please read their terms of use and privacy policies to
understand their privacy practices.

Links to Third Party Websites

Most of third party sites or other resources which are made available via our Platform provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such
documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

Cookies and Other Tracking Technologies.

When you access or use the Platform, we or our third party service providers may use industry-wide technologies such as "cookies" or other similar technologies that store certain information on your computer or device
("Cookies"), which will allow us to enable automatic activation of certain features and make your experience much more convenient and effortless. We or our authorized third party service providers may use both session
cookies (which expire once you close the Platform) and persistent cookies (which stay on your system until you delete them). It is easy to disable or delete Cookies. Most browsers will allow you to erase cookies from
your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you disable or erase cookies, your online experience may be limited. Cookies usually store only a
Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc. VDROOM does not control such third party service providers.

International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries
or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your
jurisdiction, and you consent to such transfer of information.

Direct Marketing

You hereby agree that we may use the contact details you provided us with (including, without limitation, e-mail address) for the purpose of providing you commercial and/or non-commercial materials related to our
current and/or future products and services. You may withdraw your consent by sending a written notice to legal@vdroom-travel.coml
or alternatively follow the instructions for removing yourself from the mailing list that are available in the message transmitted to you.

Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Platform and any information collected therein. VDROOM reserves the right to change this policy at any time, so please re-visit this page frequently. We will
provide notice of substantial changes of this policy on the homepage of the Platform and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial
changes will take effect seven (7) days after such notice was provided on our Platform or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated
“Last Revised” date and your continued use of the Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply
with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.

Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: legal@vdroom-travel.coml.